Privacy Statement

Introduction

The Pensions Council respects your privacy and is committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR). This privacy statement informs you what personal data we process, how we receive it, why we use it, and about your privacy rights.

Who we are

The Pensions Council was set up to advise the Minister for Employment Affairs and Social Protection on matters relating to policy on pensions. The Council is to represent and protect the consumer interest and help to ensure that the system has a far stronger consumer focus. 

The Pensions Council is the controller and responsible for your personal data (referred to as “the Council”, “we”, “us” or “our” in this privacy statement).We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy statement. If you have any questions including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Data Protection Officer
The Pensions Council
Verschoyle House
28/30 Lower Mount Street
Dublin 2, D02 KX27

Email: dpo@pensionsauthority.ie
Phone: (01) 676 6179

How we receive personal data

Personal data may be received by the methods listed below:

  • by phone, email or other written correspondence, and meetings
  • when requesting and receiving information from suppliers in response to procurement processes and supplier management 
  • through management of Council members and maintenance of HR records and IT systems

Why we use personal data

We only use personal data for the following purposes:

  • management services including:
  • procurement processes and supplier management
  • management of Council members
  • policy services including consultations or requests for information from pension stakeholders

We do not use your personal data for automated decision-making.

 The personal data we process

Personal data means any information relating to an identified or identifiable living individual. The categories of personal data defined by GDPR include identification data (e.g. name, address, emails), marital status, financial data, connection data (e.g. IP addresses) and also includes special categories of personal data for more sensitive information such as PPS numbers and trade union membership.

Cookie Policy

Information on the cookies we collect via our website is available in our Cookie Policy.

A list of the categories of personal data we hold for various types of data subjects and the legal basis for the processing of this data is provided in the table below.

Data   subjects

Categories   of personal data includes

Lawful   basis for processing

Suppliers of goods and services to the Council.

• Identity and contact data   • Banking data

Where any such processing is necessary for the performance of a   contract.

Council members, ex-members, and applicants for membership.

• Identity and contact data  • HR records   • IT records

Where any such processing is necessary for the performance of   employment contracts; to comply with legal and regulatory obligations or   where it is necessary to comply with our obligations under employment and   social security and social protection law.

Pension stakeholders including pension providers, industry bodies, and   Government Departments and bodies.

  • Identity   and contact data

Pension stakeholders consent to the processing of their personal data   by the Council in order to allow the Council to communicate with them and   deal with any information provided by stakeholders.

Members of the public who contact our information service with pension   enquiries.

• Identity and contact data  • Any data that the public may share with the Council as part of their   contact with the Council (e.g. job status or pension details)

The Council   cannot provide information or advice on pensions to individuals or   groups. However it is possible that   members of the public may nonetheless contact the Council and need to be   directed to another body or a Government Department. Members of the public consent to   the processing of their personal data by the Council in order to allow the   Council to communicate with them and deal with their queries.

Who we share your personal data with

As part of our legislative remit to provide advice to the Minister we may need to share your personal data with third parties. In most cases, if data is shared, it would be with the Department of Employment Affairs and Social Protection (the Council’s parent department). We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not permit our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. They may only process this data for the purposes of providing us with their services and no other purpose. Below is information on the names and categories of third parties with which we share personal data and the reasons for sharing.

Third   party

Reasons   for sharing data

Department   of Employment Affairs and Social Protection

To   assist and report to our parent department, as required.

Other   regulators or supervisory authorities

Where   there is a legislative basis to exchange information such as under the   Pensions Act

Service   providers who provide the Council with support services (including IT managed   service providers, software development contractors, data analysts, document   storage and destruction companies, recruitment services, website management   providers)

To   allow for the performance of a contract

Our website uses services provided by Google, including Google Custom Search and G Suite for Business. Google may store information on servers outside the European Economic Area (EEA). Google is certified under the EU-US Privacy Shield Framework

Our website is hosted on Amazon Web Services (AWS) servers and may transfer data outside the EEA. AWS is certified under the EU-EU Privacy Shield Framework.

How long we keep your personal data

We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below:

Access to your personal data

You have the right to request a copy of the personal data we hold about you together with other information about our processing of that personal data (known as a “subject access request”).

Correction of your personal data

You have the right to request that any incomplete or inaccurate data we hold about you is corrected or if we have incomplete information you may request that we update the information so that it is complete. We may need to verify the accuracy of the new data you provide to us.

Erasure of your personal data

You have the right to request us to delete or remove personal data that we hold about you. We may not be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data

You have the right to object to our processing of your personal data for particular purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Restriction of processing your personal data

You have the right to request that we no longer process your personal data in certain circumstances.

Transfer of your personal data

You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

Withdrawal of consent

You may withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising your rights

If you wish to access your data please fill out the Subject Access Request form that is available under Related Files below.

Information we require to process requests

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Fees

Usually you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Response times

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact details for further information

Data Protection Officer

The Council’s data protection officer (DPO) has responsibility for ensuring compliance with GDPR. Individuals who have questions on the Authority’s compliance with GDPR can contact the DPO.

The Pensions Council
Verschoyle House
28/30 Lower Mount Street
Dublin 2, D02 KX27
Email: dpo@pensionsauthority.ie
Phone: (01) 676 6179

The Data Protection Commission

The Data Protection Commission is responsible for upholding the rights of individuals under GDPR. Individuals who feel their rights are being infringed can complain to the Data Protection Commission, who will investigate the matter, and take whatever steps may be necessary to resolve it.

Canal House
Station Road
Portarlington
Co. Laois, R32 AP23
www.dataprotection.ie
Email: info@dataprotection.ie
Phone: 1 890 252231